How to Read China's Energy Storage Permitting: Filing, Not Approval (the 2017 State Council Regulation Reserves 核准 for Catalogued Projects; a 备案 Is Complete When the Online Platform Receives the Enterprise's Basics, Project Name, Site, Scale, Content, Total Investment and Industrial-Policy Statement), What the Storage-Specific Rules Add (the 2021 Interim Rules' Filing Content Including Technology Route, Scenario, Standards, Environment and Safety, Copied to the NEA Office; Qualified Designers and Certified Equipment; Quality, Environmental and Fire Procedures Before Commissioning), the Safety Hook Written into the Filing (the 2025 Five-Department Notice and the 2025–2027 Action Plan: the Filing Document Names the Unit's Primary Safety Responsibility), the Licence Question (Business Licences Are Required Except in NEA-Prescribed Cases; the 2025 Opinion Brings New-Type Storage in Principle into the Exemption), the Grid Step (Non-Discriminatory Access for Filed Projects; Performance and Grid-Interface Tests; the Model Dispatch Agreement Filed with the NEA Office; Southern Region: Municipal-Dispatched Electrochemical Storage Under the Rules from 5 MW/1 h) and a Provincial Layer (Jilin's Annual Project Library — User-Side and Generation-Side Storage for Now Outside It — with Grid Consultation and Feasibility Study Before Entry)

Short answer. A new-type storage project in China is filed (备案), not approved (核准): the State Council's 2017 regulation reserves approval for projects in the government-approved catalogue bearing on national security, major productive-force layout, strategic resources or major public interest, and for filed projects the enterprise notifies the filing authority through the online platform before construction of its basic situation, the project name, site, scale and content, total investment and an industrial-policy statement — the filing is complete when all of that is received. The NDRC's implementing measures repeat the mechanics, require notice of a change of legal person or a major change of site, scale or content, and say other legally required procedures still apply before construction. The storage-specific layer is the 2021 interim rules: local energy authorities file storage projects and copy filings to the NEA's dispatched office; the filing content adds technology route, application scenario, functions, standards, environment and safety; designers, consultants, builders and supervisors must be qualified, main equipment certified, and safety, fire and environmental procedures followed; grid companies give non-discriminatory access to filed projects, and quality, environmental and fire procedures must be completed before grid-connection commissioning. Two 2025 documents write safety into the filing itself — the filing authority must state the unit's primary safety responsibility in the filing document, and the project must analyse safety conditions at feasibility stage and carry out a post-safety evaluation. On licences, the rules require an electric power business licence except in NEA-prescribed cases, and the NEA's 2025 opinion brings new-type storage in principle within the exemption. The grid step is performance and grid-interface tests, plans filed with dispatch, a model dispatch agreement filed with the NEA office and GB/T 36547-2024; in the Southern region, electrochemical storage directly dispatched by a municipal-level dispatch institution comes under the regional rules from the day it reaches 5 MW/1 h. Jilin shows the provincial layer: an annual project library — for now excluding user-side and generation-side storage — that a project enters only after consulting the grid company and commissioning a feasibility study. This guide reads national and one province's texts; it quotes no land, EIA-category, fire-design-review or construction-permit text specific to storage.

1. Filing, not approval: the general regime

CNWattHub reading: 'filed' is not 'permitted to build'. Article 44 of the NDRC measures and Article 10 of the storage rules both say the other procedures required by law still have to be completed before construction starts; the filing certificate is the first document in the file, not the last.

2. The storage-specific layer (2021 interim rules)

• Who files and what. Local energy authorities file storage projects under investment law and copy filings to the NEA's dispatched office; filing content includes the unit's basics, name, site, scale, content (technology route, application scenario, main functions, technical standards, environmental protection and safety), total investment and the industrial-policy statement; after filing, the project completes other construction procedures before starting; changes of legal person, major changes or abandonment are reported.
• Who builds and with what. Design, consulting, construction and supervision firms must hold state-prescribed qualifications; main equipment must pass testing and certification by qualified bodies and grid-interface equipment must meet grid-security requirements; project units must follow safety, fire and environmental management procedures.
• Grid access. Grid companies provide non-discriminatory access and connection services to filed projects; before commissioning the project completes the procedures required by national quality, environmental and fire regulations, and grid companies set out commissioning and acceptance processes.
• Policy intent. The 2021 guiding opinion asked local governments to clarify storage administration functions, optimise the filing process and issue detailed rules, urged grid companies to simplify connection procedures, issue connection opinions promptly and build the connection works, encouraged 'one-stop' service for user-side storage, and allowed new-energy projects with storage appropriate preference in competitive allocation, approval (filing) and connection sequencing.

CNWattHub reading: the storage filing asks for more than the generic one — the technology route, scenario, standards, environment and safety are additional fields — and the copy to the NEA's office is what links a provincial filing to the national regulator's view of the fleet.

3. The safety hook written into the filing

CNWattHub reading: since April 2025 the filing document itself is a safety instrument — it is where the unit's primary responsibility is written down — so a filing certificate that predates the notice and one issued after it are not the same document, and a buyer of an existing project should read the actual text of the filing.

4. The licence question

The Electric Power Business Licence Management Provisions (as published by the NEA on 18 October 2024) require anyone conducting electric power business in China to hold a licence except in special cases prescribed by the NEA, with the NEA's dispatched offices issuing licences in three classes — generation, transmission and supply; the NEA's 2025 opinion (国能发资质〔2025〕41号) says that unless otherwise provided, new-type operating entities such as distributed PV, distributed wind, new-type storage and smart microgrids are in principle brought within the scope of licence exemption, and lists compliance with the project approval (filing) system among licensees' duties.

CNWattHub reading: 'in principle' and 'unless otherwise provided' are the operative words; the exemption is a policy direction in an implementation opinion, and whether a given independent storage station needs a generation-class licence is a question for the NEA's local office, not something this text settles.

5. The grid step

CNWattHub reading: the grid step produces its own paper trail — test reports, a filed dispatch agreement, filed plans — distinct from the investment filing, and the Southern rules show that the regional 'two rules' pick up a municipal-dispatched station at a capacity threshold (5 MW/1 h) rather than at filing.

6. A provincial layer: Jilin (2025)

Jilin's interim measures (吉能储能联〔2025〕115号, 19 June 2025) add an annual project library, organised and reported by municipal authorities, from which user-side and generation-side storage are for the time being excluded: before entry the unit consults the grid company on its connection scheme and commissions a qualified consultant's feasibility study for the provincial energy bureau; filing is applied for through the provincial online investment platform; filing content includes name, unit, site, nature, total investment, planned start and completion dates, content and scale (technology route, scenario, functions, standards, environment and safety) and the industrial-policy statement; only after entry into the library do municipal authorities guide the unit to complete construction conditions and other procedures before starting. The measures also require quality and related procedures before grid-connection commissioning, grid companies to establish and improve connection service guides and management rules, and project units to assess and rectify at design life or when safety no longer meets requirements, retiring the project and reporting to the original filing authority if it still fails after rectification.

CNWattHub reading: the library is a gate that the national texts do not have — in Jilin an independent or grid-side project can be filed yet not 'in the library', and the construction guidance is tied to the library, not to the filing; user-side and generation-side storage are for now outside library management. Other provinces may run different gates; only Jilin's text was retrieved.

7. A reading sequence built from the sources

1. Regime. 备案, with other procedures still required before construction.
2. Filing content. Generic fields plus technology route, scenario, standards, environment, safety; copy to the NEA office.
3. Filing date. Before or after April 2025 — does the document name the unit's primary safety responsibility?
4. Safety file. Feasibility-stage written analysis; completion check; post-safety evaluation.
5. Qualifications and certification. Designers, builders, supervisors; equipment certificates.
6. Licence. NEA office position under the 2025 opinion's in-principle exemption.
7. Grid file. Performance and grid-interface test reports; filed dispatch agreement; filed plans; regional-rule threshold.
8. Provincial gate. Library or equivalent (Jilin: not for user-side or generation-side storage for now); grid consultation and feasibility study.
9. End of life. Assessment at design life; retirement and report to the filing authority if the project still fails after rectification.

Scope limits

This guide reads the 2017 State Council regulation and NDRC measures, the 2021 interim storage rules and guiding opinion, the April 2025 five-department notice, the 2025–2027 action plan, the licence provisions as published in 2024 and the 2025 licensing opinion, the NEA's 2024 grid-connection notice, the 2021 model-texts notice, the GB/T 36547-2024 record, the Southern region's 2025 storage rules and Jilin's 2025 measures. It quotes no land-use, EIA-category, fire design review or construction-permit text specific to storage, no grid company's service guide, filing certificate or project timeline. Not legal or investment advice.